G.R. No.

157020 June 19, 2013

REINIER PACIFIC INTERNATIONAL SHIPPING, INC. and NEPTUNE SHIP
MANAGEMENT SVCS., PTE., LTD., petitioners
vs
CAPTAIN FRANCISCO B. GUEVARRA, SUBSTITUTED BY HIS HEIRS, respondents

Facts:
Petitioner Reinier Shipping, as agent of Neptune Ship Management Services, hired
Captain Guevarra to work as master of MV NOL SHEDAR. In the course of his work on board,
Reinier Shipping sent him Notice, relieving him of command of the vessel upon the insistence of
its charterers and owners. As a result, Guevarra filed a case for illegal dismissal and damages
against Reinier Shipping and its principal. The Labor Arbiter found Guevarras dismissal illegal.
Reinier Shipping appealed to the NLRC but it, likewise, affirmed the Labor Arbiters decision.
The due date to file a petition for special civil action of certiorari fell on July 26, a Friday.
However, Reiner Shipping succeeded in obtaining an extension of 15 days, and the due date fell
on August 10, a Saturday. Consequently, Reinier Shipping filed its petition on the following
working day, August 12, Monday.
The CA dismissed the petition for having been filed out of time and ruled that it violated
the SCs A.M. 00-2-14-SC. Since August 10, the last day of the extended period, fell on a
Saturday, automatic deferment to the next working day did not apply and the petition should
have filed its petition before August 10.
Issue:
Whether or not CA erroneously ruled in dismissing the petition.
Ruling:
Yes, it did. The CAs interpretation of A.M. 00-2-14-SC is misplaced.
A.M. 00-2-14-SC clarifies the application of Sec. 1, Rule 22 of the Rules of Court when
the last day on which a pleading is due falls on a Saturday, Sunday, or legal holiday and the
original period is extended. It actually covers a situation where the due date falls on a Saturday,
Sunday, or holiday. Precisely, what such clarification wanted to address is the erroneous claim
that "the period of extension" in such a case "is to be reckoned from the next working day and
not from the original expiration of the period." The correct rule, according to it, is that any
extension to file the required pleading should be counted from the expiration of the period
regardless of the fact that said due date is a Saturday, Sunday or legal holiday.
The situation of Reinier Shipping is actually different. In this case, the due date fell on a
Saturday when courts are close, thus, Sec. 1, Rule 22 should apply. As a result, Reinier Shipping
has up to Monday (August 12), the next working day, within which to file its petition. Hence, the
petition was filed on time. And so, the Court reversed and set aside the CAs decision.